Submission by CND

To the Consultation on the Strategic Siting

Assessment Process and Siting Criteria for
New Nuclear Power Stations in the UK
November 2008
The Campaign for Nuclear Disarmament (CND) does not believe that there is any
justification for the building of new nuclear power stations in the UK. It is not in the
public interest to do so. Nuclear power is dirty, dangerous and expensive. It is also not
the answer to climate change when we need a rapid and substantial decrease in our
carbon emissions which nuclear power cannot possibly deliver. A combination of
effective alternative measures, including renewable energy sources and energy
efficiency technologies, can help tackle climate change. None of these measures involve
the dangers associated with nuclear power. By choosing to pursue nuclear power the
UK encourages other countries to do the same, further increasing the unique risks
associated with it such as:
1. proliferation of nuclear weapons
2. contamination by toxic radioactive nuclear waste
3. nuclear accidents
CND submitted a response to the first public consultation (The Energy Review 2006)
regarding nuclear power. This consultation was judged by a High Court ruling to be
manifestly unfair and unlawful [1] . On a national level we declined to be involved in a
second consultation as, along with other organisations, we believed that the process was
biased and the outcome predetermined. The experience of some of our local and
regional group members who did decide to become involved confirmed this. Not
surprisingly, Greenpeaces complaints to the Marketing Research Standards Board were
upheld when the board came to the conclusion that the market research company chosen
by the government for this second consultation had in fact breached the Code of
Conduct.
CND is very disappointed with the governments public consultation process.
Nonetheless, in this instance we feel that there are some particularly important issues
that have to be raised regarding any siting of new nuclear power stations. Specifically,
we would like to raise the following points:
Public acceptance
The Strategic Siting Assessment (SSA) criteria do not include the issue of public
acceptance around a potential new build site. Any engagement process carried out by
the nominator of the site with the local community is also not sufficiently described.
How is the local community to be defined and who is to decide on that definition? How
and by whom will the communitys response be considered?

Local authority/regional development plans

How will the siting of a new nuclear power station fit in with local authority and
regional development plans? This should also be a criterion of a Strategic Siting
Assessment.
Other energy uses
Consideration should be made of whether other energy plans are a more appropriate use
for each site and for the region as a whole particularly given the considerable time and
resources required to build such a nuclear power plant. Moreover, since it may be many
years before some sites are built on, a process should allow sites to be re-assessed for
alternative use after a certain time period.
Spent fuel storage
Storage facilities for spent nuclear fuel must also be considered, particularly if spent
nuclear fuel is to be stored safely on a site for at least 100 years before any long-term
repository might become available. There is still no safe solution for nuclear waste
storage since no such repository has yet been built anywhere in the world and plans are
still on paper. Moreover, uncertainties around storage will be increased by the likely use
of high burnup fuel in new nuclear power stations. This will produce nuclear waste that
is much more difficult to deal with, being much hotter and more highly radioactive with
an increased potential for worker and public exposure to radiation [2] .
Given that a safe storage solution is still forthcoming, and that high burn-up fuel brings
with it particular difficulties with regard to storage, spent fuel might need to be kept on
a site for even longer than 100 years. In which case any siting assessment would need to
take into account the undefined timescale for such storage facilities.
Terrorism/accidents
Emergency planning as a criterion is given only as a local consideration. Of course any
accident or deliberate act which releases radiation into the atmosphere can potentially
affect more than just the local population of a site. Depending on atmospheric
conditions, radioactive contamination knows no boundaries. As new reactor designs
being urged in the UK are untried and untested, there is even more reason to launch a
comprehensive and independent assessment and report on the possible effects of a
nuclear emergency, whether caused by a terrorist attack or an accident, at either the
reactor or the spent fuel stores. Additionally, such an assessment must include
transportation routes of nuclear material from or to nuclear power station sites.
Site demographics
In reference to any discussion related to the demographics around a site, studies must be
taken into account that continue to show that there is a higher rate of cancer around
nuclear power stations, particularly amongst children [3] .
[1]

http://www.greenpeace.org.uk/blog/nuclear/breaking-news-another-nuclear-consultation-was-fixed20081016
[2]
http://www.nuclearconsult.com/Too_Hot_to_Handle.pdf
[3]
Ian Fairlie, Comment: we ignore the evidence on cancer clusters at our peril, New Scientist;
26/04/2008, Vol. 198 Issue 2653, p18-18, 1p